Tag Archives: broadband

JAN

14 Webinar: Public-Private Partnerships for Broadband

In this webinar, CTC President Joanne Hovis, Communications Workers of America Legislative & Political State Coordinator and Local President for Louisiana Matt Wood, Greendale Indiana Mayor Allen Weiss, and AT&T President of Broadband Access and Adoption Initiatives Jeff Luong discuss public-private partnerships for the deployment of broadband.

The publication, “The Era of the Broadband Public-Private Partnership: New Trends and Opportunities in the Wake of Covid-19” was commissioned by the Communications Workers of America and published by the Benton Institute for Broadband & Society and is in our library.

Published: Friday, January 14, 2022 by CTC Technology & Energy

DEC

21 Mason County and the City of Maysville, KY, Issue Broadband RFP

Mason County and the City of Maysville, KY (the City/County) seek a partner to review the current status of broadband availability in the community; plan for the construction of an expanded network to address underserved, unserved, and unreliably served areas; and construct and operate the broadband infrastructure.

The City/County seek to empower residents and local businesses to be network economy producers and believe this project will enable economic diversification and create new job opportunities. The City/County intend to support this vision with a fiscally sustainable, scalable, and long-term solution. Responses to this RFP will ideally consider community needs not just of today, but for 10 to 15 years in the future.

Responses are due Monday, January 17, 2022, at 2:00 PM local time.

The full RFP is available here.

Published: Tuesday, December 21, 2021 by CTC Technology & Energy

OCT

26 USDA’s new ReConnect broadband grant rules dramatically expand eligible areas and effectively redefine broadband

Heather Mills, V.P. for Grant & Funding Strategies

With the October 25 release of a Notice of Funding Availability (NOFA), the USDA’s Rural Utilities Service (RUS) has made important changes for Round 3 of its Rural eConnectivity Program (commonly known as ReConnect).

Significant new scoring considerations include a preference for local governments

The NOFA includes a significant shift in application scoring metrics. RUS has included a preference for local governments, non-profits, and cooperatives as applicants and additional points to those applications (“including for projects involving public-private partnerships where the local government, non-profit, or cooperative is the applicant”).

Further, RUS includes metrics to score the affordability of the services being offered; whether wholesale services at non-discriminatory rates will be offered; compliance with net neutrality requirements; and willingness to include strong labor standards.

RUS has also included points for applications with service areas that encompass Socially Vulnerable Communities and those that address areas with defined economic need. (Our grants team is still evaluating these issues and will post a deep dive soon.)

However, don’t forget that this is a rural program and rurality still matters. Available speeds also matter. As such, points are awarded for serving the least dense rural areas as well as serving areas that lack 25/3 Mbps.

Any areas with less than 100/20 Mbps, even those with DSL or fixed wireless, are eligible

RUS is expanding eligible areas beyond the FCC’s 25/3 definition of broadband. The RUS’ definition of an eligible Proposed Funded Service Area (PFSA) is now one that is not currently receiving speeds of 100 Mbps download and 20 Mbps upload, a considerable and welcome change from its previous definition of 10/1. Further, in the scoring process, extra points (25) will be awarded to those applications that will serve areas that currently have less than 25/3 Mbps available. This includes the service areas of existing RUS borrowers without sufficient access to broadband.

This new approach follows the policies of the Biden Administration and the Commerce Department in moving away from the FCC’s longtime definition of broadband as 25/3 Mbps, essentially eliminating any claims from DSL and fixed wireless providers—which can generally not reach those speeds—that their services qualify as broadband. Going forward, the Administration appears to be saying, only cable and fiber can deliver the speeds necessary for communities to compete in the post-pandemic world.

RDOF areas are eligible for inclusion in PFSAs

After being shut out of Round 2 due to the need to coordinate with the FCC’s auction, RDOF areas will be included in PFSAs for Round 3. The NOFA explains that this is because “RDOF funds both operational expenses and capital expenses, while ReConnect funds only capital expenses.” Another rationale given is that the six-year timeline for RDOF funds is not sufficiently fast enough to respond to the needs created by the pandemic. The goal is to get communities wired as fast as possible.

There are some nuances to those applicants applying for funding in areas where they have also received – or expect to receive – RDOF awards. Expect a lot of questions to be asked and answered regarding the nuances, but generally, those applications including RDOF areas will need to provide additional insight into why that additional funding is needed. And if applicants are RDOF awardees, they must commit to keeping RDOF and ReConnect funding separate for tracking and reporting purposes.

This also means that those Round 2 applications that were left to die due to the sudden rule change in the curing process could resubmit in Round 3 if discussion is included on why the RDOF-awarded areas should be included in light of the pandemic.

As for existing USDA grantees or borrowers, they’re also protected as long as their protection hasn’t run out.

New Tribal/socially vulnerable set aside is a big deal – but there are strings!

New to the program is a separate funding option in which applicants can seek up to $35 million for Tribal and socially vulnerable areas. Socially vulnerable areas are those with “100 percent of locations within areas classified by the USDA Economic Research Service as FAR Level 4.” Criteria for Frontier and Remote (FAR) Level 4 areas are extremely rural or remote areas that are:

“15 minutes or more from an urban area of 2,500-9,999 people; 30 minutes or more from an urban area of 10,000-24,999 people; 45 minutes or more from an urban area of 25,000-49,999 people; and 60 minutes or more from an urban area of 50,000 or more people”[1].

Take the time to consult ReConnect’s mapping tools to confirm eligibility for these areas. And remember: It is essential to include discussion in the narrative on how the pandemic has further effected those areas and how the project will help address those issues.

It doesn’t matter what the Form 477s say, so long as the applicant can demonstrate that geographic eligibility

The NOFA includes a very clear statement that should guide your thinking on defining eligible areas:

“Applicants are not required to treat the publicly available FCC current Form 477 data as dispositive of what speed service currently exists.”

In other words, communities need to know that they’re not excluded from consideration just because Form 477 data indicates connectivity. But they need to show that they are under the 100/20 threshold.

Although the burden is on them, it’s a huge opportunity for those areas that have had bad fixed wireless networks to now participate in federal grant programs.

How should applicants prove their PFSA(s) is/are eligible if the Form 477 data isn’t “dispositive?” Use of existing mapping from NTIA (the NBAM) is an option, but is possibly limiting (because it, too, relies to some extent on the Form 477 data). Our recommendation is to act quickly (before the end of December) to do one or two essential data collection tasks:

Have the potential PFSA(s) surveyed by a qualified outside plant engineer to determine:
- Availability of services
- Status of need for make-ready (for potential aerial installations)
Issue an online speed test survey to collect:
- Information about those with service and real-time speeds
- Information from those who wish to report they do not have service

These efforts would immediately provide your application with the necessary backup required to validate the efficacy and eligibility of your PFSA. It will also help the RUS application reviewers make easy work of your application.

Like other broadband funding programs, the application should be pandemic-centric

Applicants should focus their narratives on not only the need for broadband, but the need for broadband in light of lessons learned from the Covid-19 pandemic. Be sure to include discussion and reference to the need to “build back better.”

Additional considerations as you prepare to prepare your application:

Don’t underestimate the effort required to complete and submit your application. As we mentioned in our previous blog posts on the ReConnect program: it’s never too early to start planning and, even if your eventual application is not selected for an award, the planning will not be wasted. There are more funding opportunities for broadband infrastructure coming soon!

The ReConnect application resides on the USDA’s application portal (not grants.gov) and requires a second Level E-Authentication for all users. This means users may have to make in-person appointments at USDA field offices if an online verification is not possible. Additionally, many applicants had significant trouble setting up their accounts for Round 1 and Round 2 due to technical issues. Make account and user set-up a priority task.

It’s time to start preparing!

While we await the comprehensive application guide to be posted on the ReConnect website, here are some strategic thoughts on starting the planning process:

Develop a grant strategy. Your goal is to maximize your application’s scoring given USDA’s stated criteria. Every element of your application should speak to those criteria. Start by developing a comprehensive strategy that aligns your approach (with respect to technology, partnerships, business plan, and service levels) with what USDA is seeking to fund.
Gather the many types of information and support materials required. You’ll need a range of data and numbers—such as population statistics—to establish eligibility under the program rules and to provide content for the grant narrative. You’ll also need a wide range of supporting materials, ranging from letters from your governor to documents that demonstrate the support of the local government, prospective customers, and the business community. Our recommendation here is to go over and above; additional letters (such as from your congressional delegation, the Chamber of Commerce, and so on) can only help to demonstrate the breadth of support in the community for your initiative.
Define and refine your proposed funded service area (PFSA). Define the PFSA with a count of the number of rural premises to be connected, including homes, farms, schools, libraries, healthcare facilities, and businesses (which are important because they confer additional points in the application). Then, document the engineering methodology used to demonstrate that the PFSA lacks service and is therefore eligible for funding.
Develop and review your project’s engineering plans and cost estimates. The critical engineering task after you have defined the PFSA is to develop a conceptual design for your network—including project plan, buildout timeline, design, and diagram—and cost estimates for materials and construction. The cost estimates will become a critical input to your business plan and pro forma financials and will need to be certified by a licensed Professional Engineer under the RUS rules.
Develop a financial pro forma and business plan. The pro forma is perhaps the most important (and arduous) part of your application—it should be prepared in the format provided by USDA (which will hopefully be available soon) and should include subscriber projections and descriptions of service and pricing. To support the pro forma revenue projections, you’ll need very compelling data, ideally in the form of statistically valid market research, as well as empirical data about your or your partner’s historical success in achieving comparable market share. This is possibly the most critical item in the application, given USDA’s interest in funding projects it considers sustainable and low-risk.
Develop a market narrative, including discussion and data regarding service in the region. You’ll need to demonstrate that your services will be better and no more expensive than other services offered nearby—and present a narrative discussion of why the proposed services will be both marketable and affordable.

The recently regulated program will make available $350 million for grants (25 percent match required); $250 million for 50/50 grant-loans; $200 million for loans; and $350 million for new 100 percent grants (no match required) for Tribal and socially vulnerable communities.

The funding application window/portal will open on November 24,2021, and will close on February 22, 2022.

CTC’s grant writing and broadband strategies team are ready to assist with your grant writing and strategy needs. Please contact us if you have questions or would like to discuss how CTC can assist you.

[1] See https://www.ers.usda.gov/data-products/frontier-and-remote-area-codes/documentation/ accessed October 24, 2021.

Published: Tuesday, October 26, 2021 by CTC Technology & Energy

OCT

21 NTIA’s Connecting Minority Communities Pilot Program Is a Broadband Funding Opportunity for Local Governments and Minority Serving Institutions

Heather Mills, V.P. for Grant & Funding Strategies
Lydia Weinberger, Civic Technology Analyst

Local governments and minority serving institutions (MSI) have a unique partnership opportunity in the Connecting Minority Communities (CMC) Pilot Program—which has a fast-approaching application deadline on December 1, 2021. Now is the time for local governments to speak to their MSI partners to identify potential projects.

The $285 million CMC grant program was established by the Consolidated Appropriations Act of 2021 to support MSIs and their surrounding communities. The program will fund purchasing broadband services and equipment, hiring information technology personnel, and upgrading on-campus facilities. In other words, this is not a broadband infrastructure program—it is an opportunity for local governments to fund workforce development, curriculum development, and service with their higher education partners.

Local governments can apply in partnership with eligible applicants

For purposes of applying to the CMC pilot, eligible institutions include:

Historically black colleges and universities (HBCU)
Tribal colleges and universities (TCU)
Minority-serving institutions (MSI), which include:
- Alaska Native or Native Hawaiian-serving institutions (ANNH)
- Asian American and Native American Pacific Islander-serving institutions (AANAPISI)
- Hispanic-serving institutions (HSI)
- Native American-serving nontribal institutions (NASNTI)
- Predominantly Black institutions (PBI)

The CMC pilot program also covers qualifying surrounding communities as a way to provide further support for low-income students and businesses. NTIA was purposeful with its definition of “anchor community”: Any area within a 15-mile radius of an HBCU or other MSI (other than some TCUs) that has an estimated median annual household income of no more than 250 percent of the poverty line.

For TCUs located on land held in trust by the United States that are also located within a reservation, the reservation boundary will create an area of interest (AOI) for each institution. The AOI will be used to define the institution’s anchor community boundary.

You can check out the eligibility status of your communities by consulting the CMC Anchor Community Eligibility Dashboard. If you believe the Dashboard is in any way incorrect, plan to submit supplementary information. A list of eligible HBCUs and TCUs can be found on the National Center for Education Statistics (NCES) College Navigator Website. The Eligibility Matrix for MSIs is available on the U.S. Department of Education Office of Postsecondary Education website.

Eligible costs

Take the time to understand what the CMC pilot will fund. Eligible costs include:

The purchase of broadband internet services
The installation and upgrade of campus facilities on a one-time, capital-improvement basis
The hiring and training of IT personnel
The purchase or lease of equipment and devices for student or patron use

What’s missing from this list? You cannot use the CMC pilot to fund an infrastructure build for broadband services. While the program will fund one-time upgrades to facilities, the intent is to outfit existing structures, not create new ones. The rules prohibit ground disturbance (construction) activities that require state or federal historic preservation or environmental review approvals. However, general in-building or classroom wiring, deploying fiber through existing conduit or trenches, installing wireless equipment (e.g., access points, routers), and installing wireless transmission equipment are not considered construction and therefore can be included.

Be strategic in what you include in your proposed project and its budget. The CMC pilot has an expected award range of $500,000 to $3 million. Competitive applications will most likely fall in that range. If you are asking for more than $3 million, be prepared to provide justification as to why your application is reasonable. Keep in mind that 20 percent) of grant funding is earmarked to provide broadband service or equipment to students. It makes sense that you should craft your application to mirror that structure.

Application scoring considerations

In CTC’s initial analysis of the Connecting Minority Communities Pilot Program, we noted that strong proposals would include workforce development, equipment lending, and education components, and should prioritize low-income students and community members. That is still an important framework. A well-rounded application will score better with the reviewers.

It’s worth your time to understand the scoring. The CMC Pilot will include a programmatic review to verify the proposed project’s eligibility. Then, during the merit review, NTIA’s reviewers will score each project as follows:

Project Needs and Benefits (up to 35 points): Level of demonstrated community need and how the project will address those needs
Project Purpose (up to 25 points): How the project aligns with the program’s purposes
Project Viability and Innovation (up to 20 points): The project’s technical feasibility and the organizational capability of the applicant
Project Budget (up to 15 points): The reasonableness and sustainability of the budget
Project Evaluation (up to 5 points): How the results of the project will be assessed

The two-year award period (i.e. when funds will become accessible to an awardee) is expected to begin in March 2022. More information on the CMC Pilot (including webinars and FAQs) can be found on the BroadbandUSA website.

CTC’s Grant and Funding Strategies team continues to analyze the latest developments in federal funding. Please contact us if you have questions or would like to discuss how CTC can assist you.

Published: Thursday, October 21, 2021 by CTC Technology & Energy

OCT

21 States and Localities Have Updated Guidance for Treasury’s Coronavirus Capital Projects Funds

By Heather Mills, V.P. for Grant & Funding Strategies

The Treasury Department released new guidance on its long-awaited, $10 billion Coronavirus Capital Projects Fund program—an extremely flexible opportunity that will deliver funds to each eligible state, territory, and tribal entity. State governments will now work with Treasury to receive their allocations—so now is also the time for local governments to advocate at the state level for their key broadband projects.

What can these funds be used for?

As we noted back in May, this program will deliver guaranteed funding to the states for the purpose of ensuring “access to the high-quality modern infrastructure, including broadband, needed to access critical services.” (See Treasury’s Allocation Information for a list of allocations by state, territory, and tribal area.)

The updated guidance issued gives us a clear picture of the kinds of projects Treasury has in mind—and that state governments will thus be considering as they decide how to allocate their funds:

“The COVID-19 public health emergency highlighted that access to high-quality internet can enable work, education, and health access, and that individuals and communities that lack affordable access to such high-quality internet are at a marked disadvantage. Investing in broadband for communities sensitive to or that have historically experienced these inequities will be critical for improving digital equity and opportunity, especially in the case of communities that currently lack access to the affordable, reliable, high-quality broadband internet that is necessary for full participation in school, healthcare, employment, social services, government programs, and civic life.”

The program will allow funds to be used for costs that fit in one of three main categories:

Broadband Infrastructure Projects: “[C]onstruction and deployment of broadband infrastructure designed to deliver service that reliably meets or exceeds symmetrical speeds of 100 Mbps so that communities have future-proof infrastructure to serve their long-term needs.”
Digital Connectivity Technology Projects: “[P]urchase or installation of devices and equipment, such as laptops, tablets, desktop personal computers, and public Wi-Fi equipment, to facilitate broadband internet access for communities where affordability is a barrier to broadband adoption and use.” You read that right: Affordability matters. Those who can’t afford to pay for services, even if available, are considered unserved.
Multi-Purpose Community Facility Projects: “[C]onstruction or improvement of buildings designed to jointly and directly enable work, education, and health monitoring located in communities with critical need for the project.”

Proposals for all projects need to address the ability to do work, education, and health monitoring remotely. While fulfilling these requirements may feel intuitive for category 1 (Broadband Infrastructure Projects) and category 2 (Digital Connectivity Technology Projects), category 3 requires expansion of our concept of libraries, community centers, and health centers—as well as a retooling of the scope of services these institutions can offer.

Devices funded by the program can’t be locked with filters and they can’t have usage caps that would hinder household needs.

Multi-purpose Community Facility Projects will require legwork by agencies involved in the design to institute appropriate privacy and confidentiality controls. This process would include both virtual and physical considerations and should ultimately make it easier for patrons to access healthcare, education, and work.

Affordability and Speed as a focal point

Unique to this program is the focus on determining where affordability is a barrier to broadband adoption and use and an emphasis on the importance of providing 100 Mbps symmetrical speeds. If you haven’t done so already, make sure you incorporate affordability in your planning. It will be essential to your project justification and documentation of community need, as well as the way you track the project’s progress in addressing those needs. Additionally, an eligible area is defined simply as one that cannot receive affordable, reliable, fixed wireline service of at least 100/20 Mbps. Further, RDOF-awarded areas are eligible if the service being provided is not affordable or at or above 100/20.

For infrastructure projects, the unit of analysis is not individual households, but communities. This means low-income and other communities not being well served by the private sector can be targeted without worrying about exact boundaries of served and unserved. Treasury suggests providing a list of federal sources (such as census data) to document the need, but if you have local data on social and health indicators, that would be even better. Your mapping should utilize a community focus to aid in analysis of priority areas.

How can your locality benefit from this program? And what should you be doing now?

Keep in mind that this is not a competitive grant program at the source (Treasury). Rather, the prioritization and distribution of allocated funds will occur at the state, territory, or tribal government level. For localities with candidate projects, a lot will depend on the states, territories, and tribal governments, and their decisions to apply for the funding.

Also, while it feels like a done deal that every eligible entity will apply, there may be exceptions. And while there is time for localities to get their ideas to their state governments to be considered a “subrecipient” of funding, the states are not required to reach out for ideas from localities. Make sure you get in front of your state broadband office or equivalent lead agency; get your needs in front of them and get a sense of their initial thoughts on the process.

Funds are block-grant type, so they are “guaranteed” allocations for your state or other governing body. Your state has enormous freedom in structuring the process for which projects to fund. This could mean that it either intentionally or unintentionally restricts the funding by applying outdated procedures and rules.

If a broadband office, for example, decides to award funds through its existing grant program it could end up reintroducing a funding match requirement—or an old definition of “unserved” (e.g., limiting unserved areas to those that can only receive less than 25/3 by any technology; ignoring reliability, affordability, and technology (wireline) components; or, conversely, allowing funding of projects with fixed wireless design and not taking affordability into account).

These would end up locking out the very communities that the Treasury program is aiming to serve. Make sure you talk with your state office to ensure your community’s needs are considered; that the funding process is adopted fairly; and that the process reflects the funding source’s flexibility and intentions.

So, what happens now?

Eligible entities must apply to Treasury for the funding by December 27, 2021. Once they have done so, Treasury will issue a grant agreement (remember, if the eligible state, territory, or tribal entity wants the money, they have a right to it per the ARPA law). Once the grant agreement is signed, most eligible entities will have 365 days to file a grant plan for approval by Treasury on how the funds will be used. The exception is for Tribal governments; their grant applications will serve as their grant plans. The grant plan can be revised during the 365-day period, if needed.

All funds must be expended by no later than December 31, 2026.

CTC’s Grant and Funding Strategies team continues to analyze the latest developments in infrastructure funding. Please contact us if you have questions or would like to discuss how CTC can assist you.

Published: by CTC Technology & Energy

OCT

12 New Federal Grant Opportunity for Broadband Economic Development Projects: $500 Million in New Funding with Applications Due Early in 2022

Heather Mills, V.P. for Grant & Funding Strategies
Lydia Weinberger, Civic Technology Analyst

A promising federal grant program has new funding and creates the potential for securing broadband funding to support economic development. The American Rescue Plan Act added $500 million in funding to the Economic Adjustment Assistance (EAA) program run by the U.S. Department of Commerce’s Economic Development Administration.

With the new funding, EAA represents a wide-ranging $500 million program to support planning and technical assistance projects in support of a strong and stable economy. Of that $500 million figure, $200 million is allocated to coal-impacted communities, leaving $300 million in the general pot.Grant awards will range from $500,000 to $5 million.[1]

While the EAA program has not traditionally had application deadlines, the notice of funding opportunity (NOFO) recommends submitting application packages before March 31, 2022. We recommend you treat that date as a hard deadline;the EDA team needs time to review and process applications before their funding window closes at the end of September 2022.

Eligible entities include:

Cities, townships, counties, or special district governments
State governments
Federally recognized Tribal governments
Nonprofits (excluding higher education) in partnership with a local government
Private institutions of higher education
Public and state institutions of higher education

Eligible applicants that applied for EAA CARES Act funding opportunity but were denied due to lack of funding can resubmit under the ARPA opportunity. As with the CARES Act funding opportunity, the economic impact of the coronavirus crisis is considered an eligible “special need,” and all areas of the country are eligible to apply.

If you are interested in applying, note that a Community Economic Development Strategy (CEDS) or acceptable equivalent must be in place for the intended project area; the CEDS must discuss the need for broadband; and you will need to show support from the business community.

Applicants will need to explain what steps they will “take to ensure that the economic benefits of the project will be shared by all communities in the project region, including any underserved communities.”And most important: Applicants must explain how their proposed projects will ease the economic effects of the pandemic and how they will encourage job creation—or, even better, directly create them. This program’s emphasis is the economy, jobs, and more jobs.

The grant will fund 80 percent of a proposed project. As such, applicants should be prepared for at least a 20 percent match. Higher matches will make proposals more competitive in the review process. Keep in mind as you start your planning that a wide range of technical, planning, workforce development, and public works projects are eligible for funding under this program. Building, designing, or engineering infrastructure and facilities to advance economic development strategies, or planning efforts to implement such solutions, are all considered eligible costs.

CTC’s Grant and Funding Strategies team continues to analyze the latest developments in federal funding. Please contact us if you have questions or would like to discuss how CTC can assist you.

[1] This funding is in addition to $1.5 billion added to the program by the CARES Act last year, which was earmarked for projects to address pandemic recovery.

Published: Tuesday, October 12, 2021 by CTC Technology & Energy

MAY

05 Developing a Grant Strategy in an Evolving Funding Landscape

By Ziggy Rivkin-Fish, CGEIT, VP for Broadband Strategy

Are you trying to get more secure footing in a shifting broadband landscape? You’re not alone. Between existing and potential funding programs, it’s very challenging to plan in the current moment.

For example, as we discussed in a previous paper, the results of the Rural Digital Opportunity Fund (RDOF) reverse auction and the pending rules for a range of new federal broadband funding programs have created some uncertainty about whether RDOF-awarded areas will be eligible for other streams of federal broadband funding.

This uncertainty leaves many communities’ grant planning efforts in flux at a time when Congress has allocated historic amounts of new funding for broadband infrastructure. Based on what we know now, we offer the following preliminary guidance to communities about preparing for new federal funding opportunities.

The moving pieces

Two unknowns will determine how RDOF awards will affect communities’ eligibility for other federal funding programs:

Whether the FCC will ultimately certify RDOF awardees. While the FCC technically has awarded geographic areas to auction bidders, it is still going through the process of reviewing bidders’ detailed technical and financial information. The possibility remains that the FCC could retract awards if it is not confident that a bidder will meet its commitments. In particular, fixed wireless and satellite providers’ (e.g., SpaceX’s Starlink) network designs are likely to face scrutiny.
What the new funding programs’ rules will look like. Several new broadband funding streams have been created in the past few months, including multiple programs enacted by the Consolidated Appropriations Act of 2021 and robust funding allocations included in the American Rescue Plan Act of 2021 (ARPA).

These programs are so new that their rules are still being developed by the agencies that will administer them—so we do not yet know how they will consider areas that have already received federal funds (such as RDOF awards). Some existing broadband funding programs have chosen to disregard RDOF in their latest funding rounds. For example, the Appalachian Regional Commission is not considering RDOF awards at all in the current application cycle for its Partnerships for Opportunity and Workforce and Economic Revitalization (POWER) program.

Funding streams to consider

The legislation that enabled NTIA’s new broadband funding programs explicitly stated that NTIA should coordinate with other federal agencies to ensure that the same project area is not funded by more than one agency. While there is precedent for satellite-awarded RDOF areas to be exempt from such a rule, most areas that were awarded to RDOF winners likely will be excluded from receiving funds from NTIA’s new programs.

The various broadband-relevant allocations of ARPA stimulus funding could be more attractive opportunities. The legislation itself places few restrictions on the use of the funds, simply mentioning broadband infrastructure as an eligible expense.

The $220 billion State Fiscal Recovery Fund and the $130 billion Local Fiscal Recovery Fund leave spending guidelines entirely up to state and local authorities, respectively. For the $10 billion Capital Projects Fund, guidance from the Department of the Treasury is anticipated in the near future, and will provide further information regarding restrictions and parameters.

States and localities can certainly develop their own criteria for evaluating projects and distributing ARPA funding, though, and broadband projects will have to compete against other capital infrastructure proposals and priorities. Additionally, it is highly likely that the telecom industry will lobby to prevent funding of broadband projects that would compete in their existing service areas.

Despite these hurdles, the ARPA funding presents a chance to build fiber optic infrastructure that will last for decades in areas where RDOF commitments have a high risk of not materializing, or where existing coverage is spotty or barely meets broadband speeds. In other words, areas that face challenges in qualifying for eligibility within traditional broadband funding frameworks could be viable candidates for ARPA funding.

ARPA funding could also resolve a blind spot in FCC auctions and traditional grant frameworks such as ReConnect: These types of programs typically exclude backhaul and middle-mile infrastructure that could lower barriers of entry for ISPs—which in turn could facilitate not only the extension of service to unserved areas, but also competition in already-served areas. ARPA funding could also potentially be used to pay for broadband strategic planning, including granular mapping and the development of programmatic solutions to facilitate broadband adoption.

Finally, we can consider the second round of RDOF. The FCC may fix and retain the reverse auction format, particularly if there are sufficient non-awarded areas after the first round—areas that either were ultimately rejected in the first round of RDOF or those that the FCC newly deems eligible. The auction format may yet be salvageable—if designed and executed correctly, with full and robust enforcement of bidder obligations. (That said, we hope that reverse auctions will be supplemented by more robust merit-based grantmaking at both federal and state levels, to address the inherent limitations of the reverse auction mechanism.)

The second round of RDOF, in whatever form it may take, will have a longer timeline than other federal funding sources since it will rely on the implementation of the FCC’s new address fabric and mapping data.

Even prior to the auction itself, former FCC Chairman Ajit Pai was criticized for rushing to design and execute the process, and for relying on poor and misleading mapping data to determine eligible areas. Former Chairman Pai argued that it was preferable to work quickly to solve the problem for most areas in need, and tackle the remaining areas later when better mapping data became available. This decision to conduct the auction before more accurate maps were ready has created a patchwork of isolated unserved areas, which are no longer fit for an auction format because only nearby incumbents would have a viable business case to serve them.

What should communities do?

In light of these moving pieces—and the potential funding streams—we recommend communities take the following steps to develop a funding strategy and position themselves competitively for federal dollars:

An RFP or RFI can also be an excellent vehicle for addressing community priorities. For example, it could address affordability concerns by capturing ISPs’ proposed fees and willingness to participate in subsidy programs. These elements could be considered as a scoring element for potential partners.

Explore potential partnerships. If you already know the areas of your community that are served and unserved by broadband, reach out to potential partners directly or write a request for proposals (RFP) or a request for information (RFI) to get a better understanding of potential partnerships. It can be a good strategy to target larger geographic areas at the outset and refine the service area later to reflect factors such as partner priorities, community need, and funding eligibility.

Additionally, any critical anchor institutions such as public housing, community centers, or first responder units that lack adequate connectivity can be included as priorities in the RFP or RFI. Lastly, the RFP/RFI document or the contract agreement with a partner can include performance and auditing requirements as a partnership condition.

Additionally, any critical anchor institutions such as public housing, community centers, or first responder units that lack adequate connectivity can be included as priorities in the RFP or RFI. Lastly, the RFP/RFI document or the contract agreement with a partner can include performance and auditing requirements as a partnership condition.

Throughout this process, do not limit yourself to working with incumbent service providers. If there are RDOF areas in or near your community, you can use the FCC auction results portal to see which ISPs bid in various auction rounds. Even if they did not win the auction, these providers may be willing to build in your community if sufficient support is available.

Develop a community mapping initiative. If a broadband mapping effort is not already underway in your community, it would be a valuable project to pursue. In some cases, especially if there is a potential partnership on the table, incumbent ISPs will share their actual network maps. The local school district may also have data about which neighborhoods have broadband gaps.

Creating a robust mapping effort to identify served and unserved areas is not just critical for identifying areas eligible for federal funding, but also for having the capability to challenge provider claims when the new FCC mapping program—which will rely on providers’ data—comes online. The FCC’s draft rules for the process explicitly give local governments the ability to challenge providers’ service claims.

Watch for updates from the FCC. It is prudent to keep a close eye on FCC announcements of RDOF bidder certifications or denials, to understand whether any areas will open up for second-round bidding (or other funding) in your community.
Build support for a broadband project. Finally, make sure your executive stakeholders are in the loop and supportive of project priorities. At minimum, you may need their approval, and you may need a pool of matching funds available, too, depending on the funding program. It is never too early to start having internal conversations about how to gather community resources behind a potential broadband initiative.

CTC’s Grant and Funding Strategies team continues to analyze the latest funding developments. Please contact us if you have questions or would like to discuss how CTC can assist you.

Published: Wednesday, May 5, 2021 by CTC Technology & Energy

FEB

06 Facilitating Gigabit Fiber Buildouts Report Featured in Broadband Communities Magazine

BBmag

Last month, we published our report for Google, in which we layout the fundaments in a “How-to” strategy guide for facilitating a Gigabit Community. Since, we have received great feedback from the community including tweets from the Head of Community Affairs for Google and other industry pundits whom are promoting our work. This month, we are proud of our report making the cover of Broadband Communities magazine which is also highlighting our report as the Editor’s Choice for the month.

Download the full report here [PDF].

Published: Thursday, February 6, 2014 by CTC Technology & Energy

JAN

31 CTC Technology & Energy to Aid Albuquerque in Building the City’s Network Design and Implementation

CTC Technology & Energy has helped hundreds of cities nationwide to evaluate and build the business case for municipal broadband networks. Albuquerque is the latest City to tap CTC Technology & Energy’s expertise and we are proud to work with the City. We will develop a strategy for providing a network connecting the City’s key stakeholders and locations that will have the most impact on its economic development and digital inclusion goals.

Based on CTC Technology & Energy’s kickoff meeting with the City, we plan on surveying candidate network routes and develop a system-level design and pricing estimates for the construction and operation of fiber infrastructure. We will also develop a system-level design for the use of WiFi and other last mile technologies to meet the City’s digital inclusion objectives. Our strategic design will maximize potential economic development, minimize budgeting risks, and position the City for future network expansion upon future funding availability. CTC Technology & Energy will then provide a framework for the City’s procurement process to identify an expert partner for the proposed fiber and wireless construction.

Published: Friday, January 31, 2014 by CTC Technology & Energy

JAN

23 Gigabit Communities: How Local Governments Can Facilitate Private Investment in New Gigabit Networks

Local governments have long pioneered efforts to expand broadband availability and competition; for more than a decade, they have tested public projects and public–private partnerships to deliver new broadband to their citizens. As they look to the future, communities can choose to build their own broadband networks or can work toward new partnerships with private broadband deployers. Among the models for partnership is one in which a community works to facilitate new private investment in gigabit-speed networks by optimizing available assets and processes at key touch-points in the construction cycle.

Our analysis is based on our work since 1996 assisting states and localities to plan, design, and build broadband networks. Based on that experience, we recently wrote a detailed analysis of these strategies (see our Gigabit Communities page) and below, we summarize some of the steps communities can take in such a partnership.

But we caution that these strategies are merely one side of a successful equation—and if there is not another side to the public-private partnership, local government efforts are unlikely to bear fruit. Indeed, unless the private partner is truly committed to building gigabit-capable networks, these strategies may serve merely to transfer some costs of doing business from an incumbent phone or cable company to the public.

Simply stated, the key ingredient for public-private partnership in gigabit deployment is true partnership between a locality and a willing and able private partner—one that is committed to building next-generation infrastructure rather than simply reducing costs on existing, inadequate legacy networks.

In brief summary, some of the strategies localities can undertake in partnership with private broadband deployers fall into three general categories:

1. 1. Facilitating access to key assets such as fiber, conduit, utility poles, and real estate
  2. Making available useful information
  3. Streamlining and publicizing essential local processes

These categories are described briefly here, with representative examples. Extensive additional examples, case studies, and engineering analysis are included in our full report.

STRATEGIES FOR ACCESS TO KEY ASSETS

One of the biggest challenges in bringing better broadband access to more people is the cost of building the networks. New network deployments benefit from quick access to existing fiber optics, utility poles, underground cable conduit, and real estate where equipment can be located. These assets reduce the provider’s construction costs (or the locality’s, in the event the infrastructure is for a public project). The local community can take steps to make existing assets available—and lessen the time and effort required to use them. Access to dark fiber, underground conduit, and real estate all time and cost saving strategies communities can use to help expedite construction.

In our view, access to fiber and conduit is the single most powerful tool a locality can use to incent construction of new fiber networks. The most important recommendations we have ever given our clients is to build conduit and fiber whenever the opportunity presents itself—those assets can support local governments’ own internal networks and, if sufficiently robust and extensive, can serve as the core for private deployment of new gigabit networks.

There are a range of strategies for building fiber/conduit assets locally, many of them very cost-effective if planned comprehensively. For example, the locality can require “dig-once” practices, in which both public and private entities build their fiber/conduit when other projects are underway—building fiber when the streets are already undergoing construction for other reasons makes for more efficient network construction. At the same time, the community benefits by reducing traffic disruptions from construction and protecting roads and sidewalks from life-shortening cuts.

Another critical need in broadband deployment is access to utility poles. Optimally, the network builder needs a swift “make-ready” process to prepare the poles for new fiber. In most communities, the poles are owned by phone and electric companies, which control both fees and time frames for new fiber attachments. Localities, however, can encourage private pole owners to consolidate attachments; reserve pole space; and undertake other steps that may reduce make-ready time and costs—thereby reducing the average cost of aerial fiber construction.

A further challenge is entry into a building or development. Localities can require by code—or incentive—that developers build additional pathways from the public rights-of-way to an in-building demarcation as well as internal, standards-compliant building cabling or cable pathways.

STRATEGIES FOR INFORMATION ACCESS

Most localities already devote considerable resources to data collection. Some data sets already have on hand can be made available to network deployers. With this information, it becomes easier, faster, and cheaper to plan large-scale broadband construction projects. Similarly, by making available data regarding their existing fiber and conduit, localities can enable providers to lease public fiber and conduit as part of their network designs.

Existing Geographic Information Systems—advanced mapping systems with high-resolution detail—can serve new purposes that weren’t previously contemplated. For example, GIS data on buildings, streets, utilities, zoning, and a host of other layers can be enormously helpful to construction project managers as they examine options and determines what assets are needed to plan and to build.

STRATEGIES FOR PROCESS EFFICIENCY

As with any large-scale project, smooth processes enhance broadband deployment. At the same time, localities have to balance the needs of broadband providers with the public cost of the processes necessary to support them and with other priorities that clamor for the same resources. Unlike a private sector partner, a locality cannot focus its internal processes and efforts on one single end goal; local governments are responsible for impacts throughout their communities that do not concern the broadband industry.

One way to balance these competing interests is to make processes standard and easily identifiable. Such strategies enable localities to facilitate broadband projects without sacrificing their ability to simultaneously attend to other projects and priorities. For example, timelines can be determined based on local needs, publicized, and then met. Whether a community commits to review permit applications within three days or 10 days or 20 days, that commitment can be publicized and then consistently met. Transparency about processes and timelines enables broadband companies to expeditiously plan and deploy networks, and enables localities to manage the costs and burdens of the processes necessary to meet broadband providers’ needs. Government and provider stakeholders can cooperatively plan before construction so as to understand respective schedules and needs, and so that the provider can plan to stage its work around known and predictable local processes.

Our full, detailed report on this topic can be found here. The report was prepared with sponsorship from Google, but the content represents our independent view and we are solely responsible for the analysis. Our thanks to Google for the support that enabled us to write this report, which we hope will serve to advance gigabit network deployment, a cause we consider fundamental to the national interest and to the interests of our local communities.

Joanne Hovis, President
Andrew Afflerbach, Ph.D, PE, CEO